Sanctions policy

Maxwer Group is committed to complying with all applicable economic and trade sanctions laws and regulations. This policy outlines our commitment to ensuring that our company does not engage in any transactions or dealings that violate these laws and regulations.

This policy applies to all employees, officers, directors, agents, contractors, and any other person acting on behalf of Maxwer Group, regardless of their location or position.

Maxwer Group strictly prohibits any transactions or dealings that violate applicable economic and trade sanctions laws and regulations. This includes, but is not limited to, the following:

• Engaging in transactions with individuals or entities that have been designated on any applicable sanctions list, including the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) Specially Designated Nationals and Blocked Persons List (SDN List), the United Nations Security Council Sanctions Lists, the European Union’s Consolidated List of Sanctions and the Consolidated List of the the State Secretariat for Economic Affairs of Switzerland (SECO).
• Facilitating transactions on behalf of individuals or entities that have been designated on any applicable sanctions list or providing any support for their prohibited activities.
• Engaging in transactions or dealings with countries or regions that are subject to comprehensive sanctions, such as Cuba, Iran, North Korea, and Syria.
• Engaging in transactions or dealings involving prohibited goods or services, such as arms and related material, dual-use items and goods and technology controlled for export.
• Taking actions that are intended to evade or circumvent applicable sanctions laws and regulations, including structuring transactions to avoid sanctions-related restrictions.

All employees, officers, directors, agents, contractors, and any other person acting on behalf of Maxwer Group are required to comply with the following requirements:

• Adhere to all applicable economic and trade sanctions laws and regulations.
• Conduct appropriate due diligence and screening to ensure compliance with applicable sanctions lists and restrictions, including screening of customers, suppliers, and other business partners, as well as screening of transactions and payments.
• Obtain prior approval for any transactions or dealings that may involve sanctions-related risks or restrictions.
• Report any suspected or actual violations of this policy or applicable sanctions laws and regulations to Maxwer Groups compliance officer.
• Participate in regular sanctions compliance training and education programs to enhance awareness and understanding of this policy and related compliance requirements.

Maxwer Group takes all allegations and reports of sanctions violations seriously and we will promptly investigate any suspected or actual violations. Any employee, officer, director, agent, contractor or any other person acting on behalf of Maxwer Group found to have violated this sanctions policy or applicable laws and regulations may be subject to disciplinary action, up to and including termination of employment, as well as civil or criminal proceedings.

We reserve the right to amend this sanctions policy at any time. We will communicate any changes to all employees, officers, directors, agents, contractors and any other person acting on behalf of Maxwer Group by publishing the police online.

This policy was last updated on March 31, 2023.